Epstein Secrets

Id. Prince Sultan and Prince Turki both move to dismiss the complaints against them in Ashton v. Al Qaeda Islamic Army. 02 Civ. 6977 (S.D.N.Y.); Barrera v. AI Qaeda Islamic Army, 03 Civ. 7036 (S.D.N.Y.); Burnett v. AI Baraka Inv. & Dev. Corp., 02 Civ. 1616 (D.D.C.); Burnett v. Al Baraka hrv. & Dev.

0 (hereinafter "Supp. Al-Wohai- bi Aff."). a. Status of the PIF In Filler v. Hanvit Bank, a case with facts very similar to those presented here, the Second Circuit reiterated Dole Food's requirement of direct ownership for instru- mentality status. Two defendants were commercial banks majority-owned by the Ko

t of the Princes’ ac- tions. [22-24] Pursuant to the Second Cir- cuit’s instruction, the Court must first de- termine whe

ll. Id. Prince Sultan and Prince Turki both move to dismiss the complaints against them in Ashton v. Al Qaeda Islamic Army, 02 Civ. 6977 (S.D.N.Y.); Barrera v. Al Qaeda Islamic Army, 03 Civ. 7036 (S.D.N.Y.); Burnett v. Al Baraka Inv. & Dev. Corp., 02 Civ. 1616 (D.D.C.); Burnett v. Al Baraka Inv. & Dev. 3

very least, discovery should be ordered circumspectly and only to verify allega- tions of specific facts crucial to an immuni- ty determination.”)). The Second Circuit has instructed “that generally a plaintiff may be allowed limited discovery with re- spect to the jurisdictional issue; but until [plaintiff] has sho

bia’s relationship to NCB. The Supreme Court and Second Circuit agree that there are certain circumstances in whi

Accordingly, the only dispute regarding SHC’s status is whether it is an organ of the Kingdom. In Filler v. Hanvit Bank, 378 F.3d 213 (2d Cir.2004), the Second Circuit considered various factors to determine whether an entity could be considered an organ of a foreign sovereign. Jd. at 217. The factors include: (1)

deral complaint by Taha Al-Awani, Muhammad 392 F.Supp.2d 539, 10 A.L.R. Fed. 2d 789 Footnotes 1 SHC moves to dismiss the Ashton, Burnett, Federal, Barrera, and Salvo complaints. The Court consolidated Barrera v. al Qaeda Islamic Army, 03 Civ. 7038, with Ashton on December 6, 2004. Similarly, at Plaintif

ictment are so general that they do not advise the defendant of the specific acts of which he is accused." United States v. Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quotations marks and citation omitted); see also, e.g., United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug.

vidence or witnesses to be offered prior to trial."' (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as to identities of unnamed victims of alleged murder conspirac

ictment are so general that they do not advise the defendant of the specific acts of which he is accused." United States v. Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quotations marks and citation omitted); see also, e.g., United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug.

evidence or witnesses to be offered prior to trial." (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as to identities of unnamed victims of alleged murder conspirac